U.S. Treasury and FinCEN Increase Focus on Healthcare Fraud

By: Aaron E. Kacer and Steven T. Lawrence On March 30, 2026, the U.S. Treasury and the Financial Crimes Enforcement Network (FinCEN) announced a new coordinated policy aimed at fraud schemes that intend to exploit Medicare, Medicaid, and other federal and state healthcare benefit programs.[1] The new policy includes (i) FinCEN advisory describing common healthcare…

Healthcare Vendor Arrangements – Buyer Beware

Healthcare Vendor Arrangements – Buyer Beware

Physician groups are frequently approached with “business opportunities” that sound routine, such as equipment leases, administrative services agreements, space rentals, and networking events. But all too often, those offers are really just dressed-up referral schemes that can land physicians in trouble. Two recent federal cases are important reminders that when it comes to vendor relationships,…

Arizona Employer Form I-9 compliance

Form I-9: Not Merely An Administrative Task, But A Legal Obligation

By: Desalina A. Williams and Jodi R. Bohr Every employer in the United States is required by federal law to properly complete a Form I-9: Employment Eligibility Verification (commonly referred to as “Form I-9”) for each employee.[1] To satisfy this requirement, employers must: Use the current, unexpired Form I-9. At the time of publication, the…

DEA and HHS Further Extend Telemedicine Rules for Prescribing Controlled Substances

The U.S. Drug Enforcement Administration (DEA) and the Department of Health and Human Services (HHS) have issued a fourth temporary extension[1] (the “Fourth Temporary Extension”) of rules that allow providers to prescribe controlled substances via telemedicine without an initial in-person exam through December 31, 2026. These rules, first introduced during the COVID-19 public health emergency,…

Does your healthcare practice use employment agreements with non-compete provisions? If so, your practice may be a target of the FTC.

By: Desalina A. Williams and Jodi R. Bohr In 2024, the Federal Trade Commission (the “FTC” or “Commission”) finalized a rule that prohibited noncompete clauses in employment agreements.[1] This rule sparked significant discourse across various industries. However, the rule was never enforced because a Texas federal court issued a nationwide injunction blocking the FTC’s rule…